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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`DELL INC., EMC CORPORATION, HEWLETT-PACKARD
`ENTERPRISE CO., AND HP ENTERPRISE SERVICES, LLC,
`Petitioner
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`v.
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`REALTIME DATA LLC
`Patent Owner
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`____________
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`Case IPR2017-00176
`Patent 7,161,506
`____________
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`MOTION FOR ADMISSION PRO HAC VICE OF
`KAYVAN B. NOROOZI
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`I. RELIEF REQUESTED
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`Case IPR2017-00176
`U.S. Pat. No. 7,161,506
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Realtime Data LLC
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`(“Realtime”) respectfully requests that the Patent Trial and Appeal Board admit
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`Kayvan B. Noroozi pro hac vice in this proceeding, IPR2017-00176. Petitioner has
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`indicated it will not oppose this motion.
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`II. GOVERNING LAW, RULES, AND PRECEDENT
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`Section 42.10(c) provides that “where lead counsel is a registered
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`practitioner, a motion to appear pro hac vice by counsel who is not a registered
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`practitioner may be granted upon a showing that counsel is an experienced
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`litigating attorney and has established familiarity with the subject matter at issue in
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`the proceeding.”
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`III. STATEMENT OF FACTS
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`The facts here satisfy § 42.10(c) and demonstrate good cause for the Board
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`to recognize Mr. Noroozi pro hac vice in this proceeding.
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`Lead counsel, Jason Eisenberg, is a registered practitioner. Counsel, Kayvan
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`B. Noroozi, is an experienced patent litigator in good standing with the California
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`State Bar and admitted to practice before the United States District Courts for the
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`Eastern District of Texas and Northern District of California. (Noroozi Decl., ¶¶ 1-
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`2.) Mr. Noroozi is also familiar with the subject matter at issue in this proceeding
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`through his review of the underlying patent, the record, and discussions with Patent
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`Case IPR2017-00176
`U.S. Pat. No. 7,161,506
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`Owner, its counsel, and its expert witness. (Id., ¶ 8.) Mr. Noroozi understands and
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`accepts that he will be subject to the USPTO Rules of Professional Conduct set
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`forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a). (Id., ¶ 7.)
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`V. CONCLUSION
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`For the foregoing reasons, Patent Owner respectfully requests that the Board
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`admit Kayvan B. Noroozi pro hac vice in this proceeding.
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`Respectfully submitted,
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
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`/Jason D. Eisenberg/
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`Jason D. Eisenberg, Registration No. 43,447
`Counsel for Patent Owner
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`Date: February 24, 2017
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`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
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`Case IPR2017-00176
`U.S. Pat. No. 7,161,506
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that the foregoing MOTION FOR
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`ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI was served
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`electronically via e-mail on February 24, 2017 in its entirety on the following
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`counsel of record for Petitioner:
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`Andrew R. Sommer (Lead Counsel)
`Thomas M. Dunham (Back-up Counsel)
`Garth A. Winn (Back-up Counsel)
`Vivek V. Krishnan (Back-up Counsel)
`WINSTON & STRAWN LLP
`IPR2017-00176@winston.com
`garth.winn@klarquist.com
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`Respectfully submitted,
` STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
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`/Jason D. Eisenberg/
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`Jason D. Eisenberg, Registration No. 43,447
`Counsel for Patent Owner
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`Date: February 24, 2017
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`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
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